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Only 28 days left to submit comments regarding the CFPB’s proposed modifications to Home Mortgage Disclosure (Regulation C)

The Consumer Financial Protection Bureau (“CFPB”) has published for public comment, a proposed rule amending Regulation C to implement amendments to the Home Mortgage Disclosure Act (HMDA). The HMDA requires certain financial institutions to collect and report information in connection with housing-related loans and loan applications. The amendments made by the Dodd- Frank Act expanded the scope of information relating to mortgage applications and loans that must be compiled, maintained, and reported pursuant to HMDA. The CFPB proposes to amend Regulation C to add several new reporting requirements and seeks to clarify existing requirements. The general categories of the proposed modifications are as follows:

Modifications to Institutional and Transactional Coverage: This category seeks to adjust Regulation C’s institutional coverage test by adopting a uniform loan volume threshold of 25 loans for all financial institutions;

Modifications to Reportable Data Requirements: Proposal to add new data points to the reporting requirements established by Regulation C and modify certain existing data points. The data points that the CFPB is proposing to add or modify include information about applicants, borrowers, the underwriting process, the property securing the loan, features of the loan and unique identifiers including universal loan identifier and legal entity identifier for the financial institutions;

Modifications to Disclosure and Reporting Requirements: Proposal to require financial institutions with large numbers of reported transactions to submit their HMDA data on a quarterly, rather than an annual, basis;

Modifications to Clarify the Regulation: Examples of proposed clarifications include guidance on what types of residential structures are considered dwellings, the treatment of manufactured and modular homes and multiple properties, coverage of preapproval programs and temporary financing and how to report a transaction that involved multiple financial institutions, among others.

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